TL;DR

If your facility has above-ground oil storage capacity totaling 1,320 gallons or more (and could reasonably be expected to discharge oil into waters of the United States), EPA's SPCC Rule (40 CFR 112) applies. This checklist walks through what an SPCC plan covers and what to have ready for an inspection.

Legal disclaimer: This is general guidance, not legal or regulatory advice. For facility-specific SPCC plan development or review, work with a Professional Engineer (PE) or an environmental consultant who can certify the plan. Your Authority Having Jurisdiction (AHJ) and the state Department of Environmental Protection may have additional or more stringent requirements.

When SPCC applies to you

Your facility is subject to SPCC if all three are true:

1. You store oil (heating oil, diesel, motor oil, or similar)
2. Your total above-ground oil storage capacity is 1,320 gallons or more, OR your total below-ground storage is 42,000 gallons or more
3. There's a reasonable expectation oil could discharge to navigable waters or adjoining shorelines

Tanks under 55 gallons don't count toward the total. Totally buried tanks subject to UST regulations don't count.

What an SPCC plan covers

A compliant SPCC plan (40 CFR 112) should include:

Facility information

• Facility name, address, and type
• Owner/operator contact info
• Site plan showing all oil storage containers
• Location of drainage paths, waterways, and groundwater sensitivity

Tank inventory

• Each tank listed with: capacity, contents, construction, age, inspection history
• Above-ground tanks, portable containers, drums, and bulk storage all counted

Secondary containment

• Each tank should have appropriate secondary containment (dike, berm, double-wall construction, remote impoundment) sized to hold the volume of the largest single tank plus precipitation
• Loading/unloading areas need containment or diversion
• Mobile/portable containers require appropriate containment

Inspection and testing

• Monthly visual inspection records
• Annual or periodic integrity testing (STI SP001 or equivalent for above-ground tanks)
• Drainage water inspection before discharge from diked areas
• Inspection records retained at least 3 years

Personnel training

• Operators trained on: oil handling procedures, spill response, applicable regulations
• Training records kept

Security

• Fencing, lighting, valve locks appropriate to the site
• Discharge valves lockable

Spill response

• Specific response procedures for each type of discharge
• Notification procedures (internal + NRC at 1-800-424-8802)
• Cleanup procedures and responsible parties
• On-site spill response equipment

Plan certification

• Plans for facilities with > 10,000 gallons aggregate capacity must be certified by a PE
• Qualifying small facilities (under 10,000 gallons, no single tank over 5,000 gallons, good spill history) can self-certify under a simpler Tier I or Tier II template

Plan review

• Reviewed at least every 5 years
• Amended within 6 months of any material change
• Kept on-site (or at nearest field office for unattended facilities)

Walk-through inspection checklist

Before an EPA or state inspector walks in, or as an internal quarterly review, walk the site with this checklist:

• [ ] SPCC plan on-site and current (reviewed within last 5 years)
• [ ] Site plan in the SPCC matches actual tank locations
• [ ] Each above-ground tank labeled with contents
• [ ] Secondary containment integrity: no cracks, no standing rainwater above discharge threshold
• [ ] Drainage valves on containment structures locked when not in use
• [ ] Monthly inspection log current
• [ ] Annual integrity test records on file
• [ ] Overfill prevention (alarm, auto-shutoff, or equivalent) operational
• [ ] Spill response kit on-site and stocked
• [ ] Training records current for operators
• [ ] Emergency contacts posted (NRC, state DEP, Fox Fuel dispatch)
• [ ] Tank nameplates and serial numbers readable

Fox Fuel's role in your SPCC compliance

We're a fuel supplier, not an SPCC consultant. But we can help:

• Delivery tickets for every fill: retained documentation of fuel type, volume, and date
• Driver training on loading/unloading procedures: our drivers follow containment and overfill procedures
• Delivery coordination around your inspection schedule: if you need to coordinate fills with tank testing or inspection windows, tell dispatch
• Emergency response during a spill: if you have a spill during or immediately after a Fox Fuel delivery, call dispatch immediately. Our driver stays on-site until secured.

What we don't do

• Write your SPCC plan (use a PE or environmental consultant)
• Certify compliance (that's on you or your consultant)
• Install or maintain secondary containment structures
• Provide legal representation during regulatory action

Practical recommendations for the first 30 days

If your facility has never formally had an SPCC plan:

1. Measure your total oil storage. Add up every tank, drum, and container.
2. Check if you exceed the 1,320-gallon threshold. If yes, you're subject to SPCC.
3. Evaluate whether you qualify for self-certification (Tier I or Tier II) or need a PE-certified plan.
4. Engage a PE or environmental consultant if you need a certified plan.
5. Walk the site using the checklist above while waiting for the plan.
6. Document everything - inspections, tests, training, incidents.

Related resources

• /services/commercial-heating-oil/
• /services/generator-fueling/
• /services/emergency-delivery/
• EPA SPCC Rule summary: https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/overview-spcc-program
• PA DEP: https://www.dep.pa.gov

Call dispatch

Call (215) 659-1616 for commercial fuel delivery in Greater Philadelphia. We coordinate fills with your tank inspection and compliance schedule.

Need a quote for your facility? Call (215) 659-1616 for commercial fuel programs across Montgomery, Bucks, Philadelphia, Delaware, and Chester counties.